From: Kevin Condon [mailto:kcondon@myfinancialadvice.net] 

Sent: Thursday, April 07, 2011 1:07 PM 

To: EBSA, E-ORI - EBSA 

Subject: Fiduciary Advice for All Plan Participants, Please. 

Those who conflate fiduciary responsibility to the plan sponsor with fiduciary advice to plan 

participants do so to preserve the status quo and market dominance of companies who 

manufacture investment products for retirement plans. Any claim that a more stringent fiduciary 

standard would deprive “rank and file” plan participants of advice is false. Companies such as 

ours are poised to provide such advice with technological solutions and economies of scale on 

the web, but we are blocked from doing so by the existing subsidy of concealed fees and the 

inertial market positioning of investment companies whose products dominate the retirement plan 

market.

 

Plan sponsors, though concerned about their liability for investment decisions made by 

investment advisors working for plan participants, actually have access to investment advice from 

many sources. Plan participants, however, are normally limited to the “guidance” provided by the 

investment companies who service the investment products provided in their plan. This has two 

flaws. First, it assumes that plan participants only need advice as to their investments. This is 

untrue. Plan participants need advice that touches investments, but also touches tax, cash flow, 

insurance, coordinating benefits selections, wealth transfer and dynamically changing family 

priorities for income and savings, due to illness, needs of other family members, etc. The second 

flaw is that the quantity of advisors available to provide advice is too small to meet expanded 

demand. This is also false. With economies of scale provided by web and phone access through 

employer’s intranet data access, fairly priced modular advice sessions can be provided to all. 

Again, provision of comprehensively useful, i.e., “real”, advice sessions is blocked by the currently 

extant product support and “guidance” services associated with companies wishing to protect the 

retirement market share they dominate. 

 

Giving “real” advice to all has not been tried and found wanting. It has never been tried. Yet every 

year the complexity and financial literacy requirements required to receive advice and implement 

it increases. 

 

Constructing and providing fiduciary advice sessions designed to meet the needs of the plan 

participant, not the investment or financial service companies now widely used in the workplace, 

is badly needed. Our company has had thousands of interactions with the public in workplace 

environments and beyond and we have developed technology and modular methods for data 

management and ease of advice delivery that can provide fiduciary advice to everyone. 

 

Kevin P. Condon

 

Kevin P. Condon, Ph.D., CFP® 

 

EVP, Advisor Services

Myfinancialadvice, Inc.

3005 Center Green Drive., Suite 115 

Boulder, CO 80301 

kcondon@myfinancialadvice.net

b 303.395.3355 104 x

m 303.906.4532

f 303.480.0059 

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